Revenue eBrief No. 023/25
24 January 2025
Controlled Foreign Company Rules
Tax and Duty Manual - Part 35b-01-01 Controlled Foreign Company (CFC) Rules has been updated to reflect the following:
- the Finance Act 2024 amendment to section 835YA of the Taxes Consolidation Act 1997 (‘TCA 1997’), which provides for Irish defensive measures in respect of the CFC rules, and incorporates the October 2024 update to the EU Code of Conduct list of non-cooperative jurisdictions for tax purposes,
- the Finance Act 2024 consequential amendment to section 835Q, and the rules for calculating the ‘undistributed income’ of the CFC, which arises as a result of the introduction of the new corporation tax exemption in respect of certain foreign distributions under section 831B TCA 1997, and
- the Finance (No. 2) Act 2023 Pillar Two related consequential amendments to the CFC rules made in respect of section 835S (Creditable tax) and section 835T (Effective tax rate exemption).